Terms Unconditional

EHR & Health Data Systems · Health Data Network / HIE · Structural / no discrete incident

CommonWell Health Alliance

Headline

CommonWell is a nationwide record-exchange network founded by EHR companies, and it is one of the ten federally designated QHINs under TEFCA.

Not independently verified. Verification status: Unverified - heuristic first draft. Publish state: draft unverified.

CommonWell is a nationwide record-exchange network founded by EHR companies, and it is one of the ten federally designated QHINs under TEFCA. When a doctor's EHR checks whether other providers hold records on you and pulls them in, networks like this do the matching and routing. Its privacy policy says its services 'may include the use and transfer of PHI.' Its data and security policy lets the Alliance or a service provider store health data 'for the sole purposes of providing the Services,' without saying what is stored, where, or for how long. Patients have no direct relationship with it and no opt-out mechanism is described: consent is left to the participating providers under applicable law. This pass found no breach or enforcement action.

  • SeveritySeverity 2 of 5, not independently verified. CommonWell is a nationwide record-exchange network founded by EHR companies, and it is one of the ten federally designated QHINs under TEFCA.
  • Evidence tierUnassigned
  • Claims confirmedNo sourced claims yet
  • Last verified2026-10-15

Primary source. www.commonwellalliance.org/data-and-security/ — Unverified - heuristic first draft.

Last verified 24 days agoverified 24 days ago0180 days
Freshness. Last verified 24 days ago (2026-10-15); stale after 180 days.

Terms

Arbitration

None. Website terms give exclusive jurisdiction to Delaware state and federal courts.

Data sharing

Locates and transmits patient records between member EHRs. May store health data and de-identified PHI to provide services. The website collects IP, device and zip-level data and uses cookies, third-party cookies and web beacons.

Who holds your data. Data chain: CommonWell Health Alliance, then Member-driven nonprofit alliance, formally incorporated as a trade association in 2013 (per CommonWell's About page; IRS tax-exempt subsection not confirmed) (parent), then EHR vendor layer. See cross-cutting finding 16: THE EHR LAYER — THE COMPANY HOLDING YOUR CHART IS ONE YOU NEVER SIGNED WITH.

Fees and billing

None (no consumer billing).

Contacts

Privacy contact. Obfuscated email on privacy page; Contact Us page on commonwellalliance.org

Legal notice. CommonWell Health Alliance, 75 Arlington Street, Suite 500, Boston, MA 02116 (contact-page address; not necessarily the registered agent for service of process)

Mailing address. Not recorded.

Written channel present
Paper trail: written. Written channel present.

Evidence

No claims have been itemized for this row yet.

Sources

SourceClaimTierStatusQuote
Organization homepage · 2026
www.commonwellalliance.org/
whole rowUnassignedconfirmed“Supporting connected healthcare through trusted collaboration and data exchange”
Quote basis: not recorded.
TEFCA RCE · 2026
rce.sequoiaproject.org/designated-qhins/
whole rowUnassignedconfirmed“CommonWell Health Alliance”
Quote basis: not recorded.
Organization privacy policy · 2026
www.commonwellalliance.org/privacy/
whole rowUnassignedconfirmed“Alliance's Services may include the use and transfer of PHI”
Quote basis: not recorded.
Organization data & security policy · 2026
www.commonwellalliance.org/data-and-security/
whole rowUnassignedconfirmed“only as necessary to provide or receive the benefit of the Services”
Quote basis: not recorded.
Organization terms of use · 2026
www.commonwellalliance.org/terms/
whole rowUnassignedconfirmed“These Terms of Use will be governed by the laws of the State of Delaware”
Quote basis: not recorded.

Source vault

Link status: Candidate - not yet fetched

DocumentLast fetchPDF
Privacy policy
https://www.commonwellalliance.org/privacy/
Not fetched yetNOT CONFIRMED
Terms of service
https://www.commonwellalliance.org/terms/
Not fetched yetNOT CONFIRMED
Website
https://www.commonwellalliance.org
Not fetched yet—
Primary source
https://www.commonwellalliance.org/data-and-security/
Verification: Unverified - heuristic first draft
Not fetched yet—

Enforcement

No enforcement actions are linked to this row.

State statute

No comprehensive state privacy statute on file for MA